Westmore · UDRP DecisionZipercruiter.com, Ziprecrutier.com, Ziprecuiter.com
The Panel ordered the transfer of three domain names comprising minor misspellings of ZIPRECRUITER. It found the domains confusingly similar to the Complainant's mark, found no rights or legitimate interests based principally on their competitive pay-per-click use and the absence of authorization or a response, and found bad-faith registration and use because the Respondents targeted the mark and used the domains for commercial links relating to competing recruitment services.
The timeline behind zipercruiter.com
Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.
How each disputed name was decided in this proceeding.
The decision illustrates a straightforward typosquatting pattern in which multiple misspellings of one mark were used in the same commercial manner. It is also useful for consolidation analysis because the Panel proceeded despite uncertainty over common ownership, relying on converging registrant details, a shared privacy service, parallel naming conventions, and identical pay-per-click use.
Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.
WIPO Arbitration and Mediation Center ADMINISTRATIVE PANEL DECISION ZipRecruiter, Inc. v. Domain Admin, Hush Whois Protection Ltd., On behalf of ziprecuiter.com OWNER, c/o whoisproxy.com / Amir Cohen, Hush Privacy Protection Ltd. Case No. D2019-2273 1. The Parties The Complainant is ZipRecruiter, Inc., United Kingdom, represented by SafeNames Ltd., United Kingdom. The Respondents are Domain Admin, Hush Whois Protection Ltd., Seychelles, On behalf of ziprecuiter.com OWNER, c/o whoisproxy.com, United States of America (“United States”) / Amir Cohen, Hush Privacy Protection Ltd., Seychelles. 2. The Domain Names and Registrars The disputed domain name <zipercruiter.com> is registered with PSI-USA, Inc. dba Domain Robot; the disputed domain names <ziprecrutier.com> and <ziprecuiter.com> are registered with Key-Systems GmbH (the “Registrars”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on September 18, 2019. On September 19, 2019, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain names. On September 20, 2019, the Registrar transmitted by email to the Center its verification responses disclosing registrant and contact information for the disputed domain names which differed from the named Respondents and contact information in the Complaint. The Center sent an email communication to the Complainant on September 20, 2019, providing the registrant and contact information disclosed by the Registrars, and inviting the Complainant to submit an amendment to the Complaint. The Complainant filed an amended Complaint on October 2, 2019. The Center verified that the Complaint, together with the amended Complaint, satisfied the formal requirements of the Uniform Domain Name Dispute Resolution Policy (the “Policy” or “UDRP”), the Rules for Uniform Domain Name Dispute Resolution Policy (the “Rules”), and the WIPO Supplemental Rules for Uniform Domain Name Dispute Resolution Policy (the “Supplemental Rules”). In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondents of the Complaint, and the proceedings commenced on October 8, 2019. In accordance with the Rules, paragraph 5, the due date for Response was October 28, 2019. The Respondents did not submit any response. Accordingly, the Center notified the Respondents’ default on October 29, 2019. The Center appointed Evan D. Brown as the sole panelist in this matter on November 5, 2019. The Panel finds that it was properly constituted. The Panel has submitted the Statement of Acceptance and Declaration of Impartiality and Independence, as required by the Center to ensure compliance with the Rules, paragraph 7. 4. Factual Background The Complainant is an online recruitment company and has been in business since 2010. The Complainant’s web-based platform is the foundation of its business, allowing employers to post jobs and manage the applicant process, as well as permitting job seekers to search and/or receive alerts regarding the latest job posts. The Complainant owns a number of trademark registrations for the mark ZIPRECRUITER in various jurisdictions around the world, including United States Reg. No. 3934310, registered on March 22, 2011, alleging a date of first use in commerce of March 4, 2010. The respective Respondents registered <zipercruiter.com> on May 19, 2015, <ziprecrutier.com> on November 6, 2012, and <ziprecuiter.com> on August 1, 2010. Since registration, the disputed domain names have resolved to pay-per-click parking pages with links to services competitive to the Complainant – relating to job posting and recruitment. 5. Parties’ Contentions A. Complainant The Complainant contends that the disputed domain names are identical or confusingly similar to the Complainant’s trademark; that the Respondents have no rights or legitimate interests in respect of the disputed domain names; and that the disputed domain names were registered and are being used in bad faith. B. Respondent The Respondents did not reply to the Complainant’s contentions. 6. Consolidation of Multiple Respondents The record does not definitively show that all the of the disputed domain names are registered by the same party, accordingly, the matter is styled as against multiple respondents. The Panel finds it appropriate that the Respondents herein be consolidated in one matter, in accordance with the Rules, for the following reasons: (i) the registrant details for the three disputed domain names are almost identical; (ii) the disputed domain names all use the same privacy protection service; (iii) all disputed domain names comprise a misspelling of the Complainant’s mark with no additional terms; and, (iv) the use to which the disputed domain names have been put is the same. Paragraph 10(e) of the Rules states that a “[p]anel shall decide a request by a Party to consolidate multiple domain name disputes in accordance with the Policy and these Rules.” Paragraph 10(c) of the Rules provides, in relevant part, that “the [p]anel shall ensure that the administrative proceeding takes place with due expedition.” 7. Discussion and Findings To succeed, the Complainant must demonstrate that all of the elements listed in paragraph 4(a) of the Policy have been satisfied: (i) the disputed domain names are identical or confusingly similar to a trademark or service mark in which the Complainant has rights; (ii) the Respondents have no rights or legitimate interests in respect of the disputed domain names; and (iii) the disputed domain names have been registered and are being used in bad faith. All three of these elements have been met in this case. A. Identical or Confusingly Similar This element requires the Panel to consider two issues: first, whether the Complainant has rights in a relevant mark; and, second, whether the disputed domain names are identical or confusingly similar to that mark. The Panel finds the Complainant has established rights in the ZIPRECRUITER mark based on the Complainant’s use of the mark as well as trademark registrations in various jurisdictions around the world. The disputed domain names are also confusingly similar to the ZIPRECRUITER mark. The only difference between the disputed domain names and the mark result from a minor misspelling. Such insignificant modifications to trademarks are commonly referred to as “typosquatting”, as such conduct seeks to wrongfully take advantage of errors by users in typing domain names into their web browser’s location bar. See, Six Continents Hotels, Inc. v. null John Zuccarini d/b/a Country Walk , WIPO Case No. D2003-0161 . “Domain names which constitute typo-squatting are confusingly similar by definition; it is this similarity which makes them attractive.” Dell Computer Corp. v. Clinical Evaluations , WIPO Case No. D2002-0423 ; see also American Home Products Corporation v. Privateer Ltd. , WIPO Case No. D2000-0455 (<addvil.com> held confusingly similar to ADVIL). For the foregoing reasons, the Panel finds that paragraph 4(a)(i) of the Policy has been satisfied. B. Rights or Legitimate Interests The Complainant will succeed under this second element of the Policy if it establishes, prima facie , that the Respondents lack rights or legitimate interests in the disputed domain names. The following facts establish the Complainant’s prima facie case: - The Respondents have not registered any trademarks for the term ZIPRECRUITER. - There is no plausible explanation as to why the Respondents would have legitimate interests in disputed domain names that are clearly associated with the Complainant’s business. - Use of the disputed domain names to set up websites with pay-per-click advertisements is not a bona fide offering of services. - The Complainant has never licensed the Respondents to use the disputed domain names, nor are the Respondents affiliated with the Complainant in any way. - The Respondents are not known by the disputed domain names. The Respondents have not responded to the Complainant’s claims and nothing in the record otherwise overcomes the prima facie showing set forth in the Complaint. Accordingly, the Complainant has prevailed under this element of the Policy. C. Registered and Used in Bad Faith The Policy requires a complainant to establish that the disputed domain names were registered and are being used in bad faith. The Policy describes several non-exhaustive circumstances demonstrating a respondent’s bad faith registration and use. Under paragraph 4(b)(iv) of the Policy, a panel may find bad faith when a respondent “[uses] the domain name to intentionally attempt to attract, for commercial gain, Internet users to [respondent’s] website or other online location, by creating a likelihood of confusion with complainant’s mark as to the source, sponsorship, affiliation, or endorsement of [respondent’s] website or location or a product or service on [respondent’s] website or location”. Because the Complainant’s ZIPRECRUITER mark is well known, and because it has been in use since before the registration of all three of the disputed domain names, it is implausible to believe that the Respondents were not aware of the mark when they registered the disputed domain names. The Panel finds, on these facts, that the Respondents targeted the Complainant and its ZIPRECRUITER mark when they registered the disputed domain names. These facts show bad faith registration of the disputed domain names. Bad faith use is clear from the Respondents’ activities of using the disputed domain names to establish websites displaying unauthorized and competitive pay-per-click links. The Complainant has successfully established the third UDRP element. 8. Decision For the foregoing reasons, in accordance with paragraphs 4(i) of the Policy and 15 of the Rules, the Panel orders that the disputed domain names <zipercruiter.com>, <ziprecrutier.com>, and <ziprecuiter.com> be transferred to the Complainant. Evan D. Brown Sole Panelist Date: November 19, 2019
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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